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Home My WebLink About19068_RadioShack_Request for Additional Assessment Letter_02.26.2019 February 26, 2019 Jeff Slosman WYSIWYG, LLC PO Box 367 Swannanoa, North Carolina 28778 jeff@nationalwiper.com Subject: Additional Assessment Request Former Radio Shack 111 Old Bee Tree Road Swannanoa, Buncombe County, NC Brownfields Project Number 19068-15-011 Dear Mr. Slosman, The North Carolina Department of Environmental Quality (DEQ), Brownfields Program has reviewed the documents submitted with the Brownfields Property Application as well as documents received from the DEQ Inactive Hazardous Sites Branch (IHSB) for the Former Radio Shack property located at 111 Old Bee Tree Road, Buncombe County. The following is a summary of the reports reviewed: Report Title Author Date Notification of Administrative Agreement Termination AMEC Foster Wheeler February 5, 2016 Quarterly Remedial Action Progress Reports #1 - #8 AMEC Foster Wheeler January, 2014 – January, 2016 REC Status Amendment AMEC Foster Wheeler May 11, 2015 Notification of REC Status Change AMEC Foster Wheeler February 13, 2015 Construction Completion Report Addendum AMEC Environment and Infrastructure January 7, 2014 Phase I Environmental Site Assessment IVI Assessment Services, Inc. November 4, 2013 Construction Completion Report AMEC Environment and Infrastructure September 20, 2013 Preconstruction Report AMEC Environment and Infrastructure August 30, 2013 Remedial Action Plan AMEC Environment and Infrastructure July 23, 2012 Remedial Investigation Report AMEC Environment and Infrastructure September 23, 2011 Former Radio Shack February 26, 2019 Page 2 Phase I Remedial Investigation Work Plan MACTEC July 2, 2010 Corrective Action Plan MACTEC February 12, 2007 Quarterly Reports of Pre-CAP Groundwater Quality Monitoring MACTEC March, June, and September, 2006 Initial Site Assessment Addendum and Report of Pre-CAP Activities MACTEC February 7, 2006 Notice of Violation NC Department of Water Quality January 14, 2005 Site Assessment Report MACTEC January 3, 2005 Phase I Environmental Site Assessment MACTEC December 9, 2004 Based on our review of these documents and information garnered from adjacent properties, data gaps were identified. Additional assessment activities, as outlined below, are required to assist in making risk management decisions for inclusion in the Brownfields Agreement (BFA). Prior to conducting field activities, a work plan should be submitted to DEQ for review and approval. The work plan should include a description of the sampling and analytical methods to be utilized and a map depicting the proposed sample locations. The most recent Inactive Hazardous Sites Program Guidelines for Assessment and Cleanup (http://portal.ncdenr.org/web/wm/sf/ihs/ihsguide) and the November 2018 DEQ Brownfields Assessment Work Plan Checklist (attached) should be followed. Further, please follow the well construction and development standards presented in the North Carolina Administrative Code (NCAC) Title 15A Subchapter 2C. Request Level 2 QA/QC data packages from a N.C. certified environmental laboratory. Collect one duplicate sample for all analysis per every 20% of samples. 1) Groundwater Sampling: Groundwater samples from monitoring wells MW-11B, MW-12C, MW- 16A, and MW-17A should be collected and analyzed for Volatile Organic Compounds (VOCs) by EPA Method 8260. Additionally, Semi-VOCs (SVOCs) by EPA Method 8270 and Resource Conservation and Recovery Act (RCRA) Metals by EPA Method 6020 should be analyzed in the sample from MW-11B. Monitoring well locations can be found in the Remedial Action Investigation Report #8 (4th Quarter 2015) dated January 13, 2016. 2) Soil Sampling: Collect a soil sample from within each of the three areas of concern (AOCs) referenced in the Remedial Investigation Report dated September 23, 2011 to assess soil conditions following remediation by the site air sparge and soil vapor extraction system (AS/SVE). Sample locations and depth intervals should coincide with previously collected samples SS-132, SS-220A, and SS-243 (3.0, 4.5, and 1.5 feet below ground surface, respectively). Soil samples should be analyzed for VOCs by EPA Method 8260, SVOCs by EPA Method 8270, RCRA Metals by EPA Method 6020, and Hexavalent Chromium by EPA Method 7199. 3) PCB Investigation: In the Phase I Environmental Site Assessment dated November 14, 2013, pooled liquid was reported beneath four transformers within the former electrical substation building (immediately south of Building 2). During a site visit conducted on February 11, 2019, DEQ was unable to access the substation building to visually inspect these transformers. Two other transformers located on site (Building 2 Basement) were labelled as Non-PCB. An attempt should be made to discern whether or not the four substation building transformers operated with PCB containing fluids. If it is revealed that the substation transformers did contain PCBs or no determination can be made, collect a soil sample from the 0 to 2 feet depth interval beneath the building slab (location central to observed staining beneath transformers) for analysis of total Former Radio Shack February 26, 2019 Page 3 PCBs by EPA Method 8082A. It is recommended that additional sample material be collected and shipped to the laboratory on hold for later analysis of congener specific PCBs if needed. 4) Please also submit a complete list of chemicals with Safety Data Sheets for the painting operation in Building 3 on property for DEQ review as well. This may be submitted under separate cover. Report and Figures: Upon receipt of analytical data, submit a summary report with a description of field activities, tabulated data in comparison to applicable screening levels, and the laboratory data packet with applicable QA/QC documentation, provide a site plan with well locations, locations of sample points, and current site structures. Provide a potentiometric map for groundwater flow and concentration maps for contaminants detected above applicable standards. Include a detailed description of current operations since the Brownfields Property application was submitted. Please note, all sample points may need to be included on the future Brownfields plat. DEQ recommends having sample locations surveyed at the time of collection for use in preparation of the Brownfields plat. Please provide the Work Plan for additional assessment activities as soon as you are able. If you have questions about this correspondence or require additional information, please feel free to contact me by phone at (704) 235-2168 or by email at cody.cannon@ncdenr.gov. Sincerely, Cody J. Cannon Brownfields Project Manager ec: William Clarke, Roberts & Stevens, P.A. Tracy Wahl, DEQ